"I'm very aware of the commonality of interests between Sea Isle
City and Strathmere," said Florio, who has a second home in Sea
Isle City. "I think the arguments are fairly forceful and
strong."

Dennis Township lawyer Mary D'Arcy Bittner represented the
islanders before the Planning Board. She will remain the group's
co-counsel.

Florio said he is still familiarizing himself with the details
of the case, but he said he found several of the island's arguments
compelling.

"The benefits to Strathmere residents clearly outweigh the
detriments to the rest of Upper Township," he said.

Courts have looked unfavorably on "tax shopping," in which towns
try to join neighbors to pay a lower property-tax rate. Strathmere
focused its argument on the contention that the island's needs were
not being served by a mainland township.

Florio said beach towns in New Jersey have made persuasive cases
in the past to split from a neglectful mainland. But locally,
Avalon Manor lost its bid to break from Middle Township after the
courts rejected the appeal in 2004. Diamond Beach dropped its
effort to merge with Wildwood Crest after Lower Township agreed to
provide more services.

Upper Township Mayor Richard Palombo said the township will
defend its position in court if necessary.

"We're not going to roll over," he said. "I'm not intimidated by
the former governor. What lawyer wouldn't say they thought they had
a good chance in court?"

Palombo noted that Florio would pay less in property taxes on
his summer home if Sea Isle absorbed Strathmere's $393 million in
taxable property. By contrast, the township estimates that school
taxes on the mainland would climb by at least 20 percent.

"I don't care what anyone says, tax-shopping is what they're
doing," Palombo said. "It has everything to do with taxes, and they
know it."